In response to the Financial Action Taskforce’s (FATF) February 2016 statements on 4 April 2016, HM Treasury updated its advisory notes on high-risk overseas jurisdictions in relation to the Money Laundering Regulations 2007.

The notes provide advice regarding the risks posed by unsatisfactory money laundering and terrorist financing controls in a number of jurisdictions and caution firms regarding the approach they should take to business related to those jurisdictions.

According to the notes, firms should consider the following jurisdictions as high risk for the purposes of the Money Laundering Regulations 2007, and apply enhanced due diligence measures in accordance with the risks:

  • DPRK (North Korea); and
  • Iran.

The FATF has identified a number of jurisdictions which have strategic deficiencies in their AML/CFT regimes. Each jurisdiction has provided a written, high-level commitment to address these deficiencies. Firms are advised to take appropriate actions in relation to the following jurisdictions to minimise the associated risks, which may include enhanced due diligence measures in high risk situations:

  • Afghanistan;
  • Bosnia and Herzegovina;
  • Guyana;
  • Iraq;
  • Lao PDR;
  • Myanmar;
  • Papua New Guinea;
  • Syria;
  • Uganda;
  • Vanuatu; and
  • Yemen.

A number of countries are no longer subject to the FATF’s on-going AML/CFT compliance process, including:

  • Algeria;
  • Angola; and
  • Panama.